Finding Text
Criteria: The requirements for matching are contained in 2 CFR section 200.306, program legislation,
Federal awarding agency regulations, and the terms and conditions of the award. The requirements for
level of effort and earmarking are contained in program legislation, Federal awarding agency regulations,
and the terms and conditions of the award.
Per review of the award documents for Certified Community Behavioral Health Clinics Program, key staff
have identified the following level of effort requirements:
Project Director at 50%
Evaluator at 50%
Any changes in the key staff including level of effort, involving separation from the projects for 3 or more
months, or a 25% reduction in time dedicated to the projects requires prior approval from SAMHSA.
Condition: During the audit, we noted that a level of effort for the Evaluator was below the 50% required
minimum by the grant agreement.
Context: The audit findings represent a systematic problem, see condition above.
Effect: By not obtaining minimum level of effort percentages, the Clinic may have level of effort not in
compliance with the requirement.
Cause: There were ineffective controls in place during the period to ensure minimum level of effort
requirement for key staff was tracking properly.
Recommendation: We recommend that the Clinic work on improving tracking system for level of effort
requirement to make sure the Organization stays in compliance. We would also recommend to contact
SAMHSA staff that is identified in the Notice of Award if there is some uncertainty to address it timely.
Repeat finding: This is not a repeat finding.
Views of responsible officials and planned corrective actions: The Organization will ensure to track
minimum level of effort requirement in regard to any key staff to stay in compliance. All invoices will be
reviewed to ensure level of effort requirements are in compliance.